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    <title>2026 (5) TMI 1555 - ITAT MUMBAI</title>
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    <description>Where sales are accepted and purchase transactions are not conclusively disproved, alleged bogus purchases do not justify addition of the full purchase value as unexplained expenditure under section 69C of the Income-tax Act, 1961; only the profit element embedded in such purchases may be brought to tax. In this ITAT Mumbai decision, the assessee&#039;s books were audited, payments were made through banking channels, and sales were not disturbed, but independent evidence of supplier genuineness was lacking. On those facts, complete disallowance was held unwarranted and the addition was restricted to 8% of the disputed purchases, with the balance deleted.</description>
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    <pubDate>Fri, 22 May 2026 00:00:00 +0530</pubDate>
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      <description>Where sales are accepted and purchase transactions are not conclusively disproved, alleged bogus purchases do not justify addition of the full purchase value as unexplained expenditure under section 69C of the Income-tax Act, 1961; only the profit element embedded in such purchases may be brought to tax. In this ITAT Mumbai decision, the assessee&#039;s books were audited, payments were made through banking channels, and sales were not disturbed, but independent evidence of supplier genuineness was lacking. On those facts, complete disallowance was held unwarranted and the addition was restricted to 8% of the disputed purchases, with the balance deleted.</description>
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